Detective Merchant repeatedly expressed his personal opinions about the defendant's guilt and speculated about facts during his interrogation of the defendant. The defendant, who was emotional and crying throughout the interrogation, now seeks to prohibit her statement from being presented at trial because the detective's improper opinion testimony would unfairly prejudice the jury against her. Allowing a law enforcement officer to offer opinions about a defendant's credibility or guilt invades the jury's role and carries more weight with jurors. The improper portions of the interrogation cannot be properly redacted without misleading the jury.
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This is a good example of our level of work. We have extensive experience litigating non-compete and tortious interference cases on both sides. We prosecute and defend these types of cases.
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We do not take anything for granted. We do not default to the same tired boilerplate pleadings. In every new case, we fashion a specific strategy for that case.
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Motion For Summary Judgment with exhibit containing the depositions and resumes of the plaintiffs in the case of :
DOLORES HALBURN and MARK HALBURN,
Plaintiffs,
v.
CITY OF HURRICANE, WEST VIRGINIA,
a municipal corporation, BEN NEWHOUSE,
individually and in his capacity as City Manager
for the City of Hurricane, CLEVELAND
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Construction, Inc. Of Nevada, and KANAWHA
STONE COMPANY, INC.,
Defendants.
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This sample opposition to motion for judgment notwithstanding the verdict for California is made on the grounds that substantial evidence supports the jury’s verdict. The sample on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, proposed order and proof of service by mail.
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This sample motion for summary judgment by plaintiff in United States District Court is filed under the provisions of Rule 56 of the Federal Rules of Civil Procedure on the grounds that no genuine dispute exists as to any material fact and the moving party is entitled to judgment as a matter of law. The sample on which this preview is based is 16 pages and includes brief instructions, a table of contents and table of authorities as well as a memorandum of points and authorities with citations to case law and statutory authority, statement of uncontroverted facts and conclusions of law, sample declaration, proposed judgment granting summary judgment and proof of service by mail.
A motion highlighting the falsity between the jury instruction in Florida that says that a judge decides a sentence, and the reality that a judge has no say in a sentence that is a minimum mandatory.
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This is one of our cases in Volusia County, Florida. Our clients - all of the defendants in the case - were sued for breach of a non-compete agreement, breach of fiduciary duty and tortious interference.
We responded with counterclaims for a declaratory judgment holding the non-compete agreement(s) unenforceable, third party claims for breach of fiduciary duty and breach of contract and a demand for indemnification.
This is a good example of our level of work. We have extensive experience litigating non-compete and tortious interference cases on both sides. We prosecute and defend these types of cases.
In every case, we have a process: First, we master the facts. Many lawyer and law firms get involved in a case and immediately focus on law. In our view, that is the wrong approach. All cases are driven by facts. Any legal strategy must be tailored to the specific facts of a specific case.
We do not take anything for granted. We do not default to the same tired boilerplate pleadings. In every new case, we fashion a specific strategy for that case.
If you have a non-compete or tortious interference case, just give us a call at 9543-32-2380. That's what we're here for.
Motion for Summary Judgment by Kanawha Stone containing the deposition and re...Putnam Reporter
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Plaintiffs,
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CITY OF HURRICANE, WEST VIRGINIA,
a municipal corporation, BEN NEWHOUSE,
individually and in his capacity as City Manager
for the City of Hurricane, CLEVELAND
CONSTRUCTION, INC. dba Cleveland
Construction, Inc. Of Nevada, and KANAWHA
STONE COMPANY, INC.,
Defendants.
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Opposition to a California summary judgment motionLegalDocsPro
This sample opposition to a motion for summary judgment in California was created by a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
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This sample motion for summary judgment by plaintiff in United States District Court is filed under the provisions of Rule 56 of the Federal Rules of Civil Procedure on the grounds that no genuine dispute exists as to any material fact and the moving party is entitled to judgment as a matter of law. The sample on which this preview is based is 16 pages and includes brief instructions, a table of contents and table of authorities as well as a memorandum of points and authorities with citations to case law and statutory authority, statement of uncontroverted facts and conclusions of law, sample declaration, proposed judgment granting summary judgment and proof of service by mail.
A motion highlighting the falsity between the jury instruction in Florida that says that a judge decides a sentence, and the reality that a judge has no say in a sentence that is a minimum mandatory.
Case Brief InstructionsYou will prepare a Case Brief on th.docxmichelljubborjudd
Case Brief Instructions
You will prepare a Case Brief on the provided judicial opinion regarding a criminal justice topic included below , CAVITT v. STATE. DO NOT USE INFORMATION FROM THE CASE BRIEF SAMPLE. The judicial opinion that you will prepare a Case Brief on can be found below. The Case Brief must include the following sections: Caption, Facts, Procedural History, Issue, Rule of Law, Holding, and Rationale. The Case Brief must be 1 page. A heading must be provided for each section of the Case Brief. Save your work as a Microsoft Word document and review the Sample Case Brief provided below.
CAVITT v. STATE Miss. 1199 Cite as 159 So.3d 1199 (Miss.App. 2015) preme court’s notation in Bounds, Bounds asserts that the judge, not the jury, set his sentence at life in prison. Id. Hence, he claims that the imposition of a life sentence by the circuit court judge created an illegal sentence that defeats the statute of limitations on his appeal. ¶ 3. In its order dated January 7, 2014, the circuit court summarily dismissed Bounds’s PCR motion—in part because Bounds failed to seek leave from the supreme court to file the PCR motion and in part because the circuit court found that his case is not excepted from the statute of limitations. On January 21, 2014, Bounds, having reviewed the circuit court’s order, filed a motion for leave from the supreme court to proceed with his PCR motion. On January 27, 2014, Bounds filed the instant appeal. Nonetheless, on June 25, 2014, the supreme court denied Bounds’s request for leave, stating: In the application for leave before this panel, Bounds merely states that his sentence was illegal. He offers no argument and does not support his contention. Bounds’s conviction and sentence were affirmed by this Court, and the mandate issued in 1972. Accordingly, we find that Bounds has failed to make a substantial showing of the denial of a state or federal right, and his application for leave should be dismissed as timebarred. Despite the supreme court’s denial of Bounds’s motion for leave to proceed with his PCR motion, Bounds has continued in his appeal of the matter. DISCUSSION [1, 2] ¶ 4. Mississippi law requires that a movant must obtain permission from the supreme court to file a PCR motion in a circuit court if the movant’s conviction has been affirmed by the appellate court on direct appeal or if the direct appeal has been dismissed. Miss.Code Ann. § 99–39– 7 (Supp.2014). ‘‘This procedure is not merely advisory, but jurisdictional.’’ Bownes v. State, 963 So.2d 1277, 1278 (¶ 3) (Miss.Ct.App.2007) (citation omitted). We have consistently held that when a movant fails to obtain the requisite permission from the supreme court, all other courts lack the jurisdiction necessary to review the movant’s PCR motion. See Doss v. State, 757 So.2d 1016, 1017 (¶ 7) (Miss.Ct. App.2000); Bownes, 963 So.2d at 1279 (¶ 4). Accordingly, both the circuit court and this Court are without jurisdiction to review Bounds’s appeal. As ...
CHARLES DYER'S NOT GUILTY VERDICT FOR THE FEDERAL WEAPONS CHARGE! Deborah Swan
Charles Dyer was set up by a member of the ARM , American Resistance Movement, by giving him what appeared to be a grenade launcher. This type of weapon is legal for Charles to won do o his firearm military training. This is the case documents of his federal charge of having a stolen military weapon in his possession. Charles demanded a jury trial. The jury found Charles not guilty!
Using the attached information, you will prepare a Case Brief on a.docxdaniahendric
Using the attached information, you will prepare a Case Brief on a recent United States Supreme Court decision regarding a criminal justice topic. You must include the following sections: caption, facts, procedural history, issue, rule of law, holding, and rationale. The Case Brief must be 1–2 pages. Save your work as a Microsoft Word document and submit it to Blackboard. Prior to submitting the assignment, review the Case Brief Grading Rubric to verify that all components of the assignment have been completed.
(Slip Opinion)
OCTOBER TERM, 2012 1
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See
United States
v.
Detroit Timber & Lumber Co.,
200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
Syllabus
SALINAS
v
. TEXAS
CERTIORARI TO THE COURT OF CRIMINAL APPEALS OF TEXAS
No. 12–246. Argued April 17, 2013—Decided June 17, 2013
Petitioner, without being placed in custody or receiving
Miranda
warn- ings, voluntarily answered some of a police officer’s questions about a murder, but fell silent when asked whether ballistics testing would match his shotgun to shell casings found at the scene of the crime. At petitioner’s murder trial in Texas state court, and over his objection, the prosecution used his failure to answer the question as evidence of guilt. He was convicted, and both the State Court of Appeals and Court of Criminal Appeals affirmed, rejecting his claim that the pros- ecution’s use of his silence in its case in chief violated the Fifth Amendment.
Held
: The judgment is affirmed.
369 S. W. 3d 176, affirmed.
J
USTICE
A
LITO
, joined by T
HE
C
HIEF
J
USTICE
and J
USTICE
K
ENNEDY
,
concluded that petitioner’s Fifth Amendment claim fails because he did not expressly invoke the privilege in response to the officer’s question. Pp. 3
−
12.
(a) To prevent the privilege against self-incrimination from shield- ing information not properly within its scope, a witness who “ ‘desires the protection of the privilege . . . must claim it’ ” at the time he relies on it.
Minnesota
v.
Murphy
, 465 U. S. 420, 427. This Court has rec- ognized two exceptions to that requirement. First, a criminal de- fendant need not take the stand and assert the privilege at his own trial.
Griffin
v.
California
, 380 U. S. 609, 613–615. Petitioner’s si- lence falls outside this exception because he had no comparable un- qualified right not to speak during his police interview. Second, a witness’ failure to invoke the privilege against self-incrimination must be excused where governmental coercion makes his forfeiture of the privilege involuntary. See,
e.g.
,
Miranda
v.
Arizona
, 384 U. S. 436, 467
−
468, and n. 37. Petitioner cannot benefit from this principle
2
SALINAS
v.
TEX.
Denial of a request for an in camera inspection to unlock a juror's state of ...Nilgün Aykent Zahour
Nilgün Aykent Zahour and SM JUROR analyze the case of People v. Kuzdzal, 144 A.D.3d 1618, 42 N.Y.S.3d 507 (N.Y. App. Div. 2016) where the defendant appealed the court's denial of an in camera inspection to ascertain a juror's state of mind when a spectator overheard two jurors refer to the defendant as a "scumbag." #JurorMisconduct
Denial of a request for an in camera inspection to unlock a juror's state of ...
motion in limine
1. IN THE CIRCUIT COURT, SEVENTH
JUDICIAL CIRCUIT, IN AND FOR
PUTNAM COUNTY, FLORIDA
v.
AMANDA K. JACKSON,
Defendant. CASE NO.; 2012-01549-CF-52
/ JUDGE CLYDE E. WOLFE
DEFENDANT AMANDA K. JACKSON’S MEMORANDUM IN SUPPORT OF MOTOIN
IN LIMININE REGARDING IMPERMISSIBLE LAW ENFORCEMENT OPINION
TESTIMONY THROUGHOUT THE DEFENDANT’S STATEMENT
Defendant Amanda K. Jackson (“Jackson”) moves this court pursuant to Fla. R. Crim. P.
3.190(a),(h) and Fla. Stat. §90.403 to prohibit presentation before the jury of her written and oral
statement based on the impermissible opinion testimony made by law enforcement throughout
the entirety of her recorded statement.
INTRODUCTION
Defendant seeks to prohibit opinion testimony made by law enforcement before the jury
based on the impermissible opinion testimony made by law enforcement throughout the entirety
of her recorded statement The testimony would cause unfair prejudice to the defendant, thus
violating her constitutional rights under the Florida Constitution and the United States
Constitution.
On August 12nd, 2012, Detective John Merchant of Putnam County Sherriff’s Office
questioned Defendant for the charge of leaving the scene of an accident causing death that
occurred on March 31, 2010. From the beginning of the interview, Defendant was extremely
emotional and she expressed her desire to see her children at her home. Throughout the
2. interrogation, Detective Merchant repeatedly expressed his opinions of Defendant’s guilt, as well
as the victim’s family life and character. Detective Merchant used several interrogation tactics,
such as mentioning Defendant’s kids and husband, which elicited an emotional response from
Defendant. Detective Merchant also made statements to diminish the criminal culpability of the
alleged offense, improperly bolstered the depth of law enforcement’s investigation, speculated
facts about the offense, and repeatedly misstated the law. Even though law enforcement is
permitted to use interrogation tactics to elicit a response from the defendant, expressing opinion
testimony and personal views to the jury is a violation of Florida case law and the United States
Constitution. Seibert v. State, 923 So. 2d 460, 472. Here, Detective Merchant expressed his
personal views on the alleged facts of the case, along with several lies that involved Defendant’s
family. This testimony would cause prejudice to the jury, which violates Defendant’s
constitutional right of due process according to the United States Constitution and the Florida
Constitution. Controlling authority does not allow the State to admit evidence where the
probative value is substantially outweighed by the danger of unfair prejudice, pursuant to Fla.
Stat. §90.403. Defendant now moves to prohibit presentation before the jury of her written and
oral statement based on the impermissible opinion testimony made by law enforcement.
STATEMENT OF FACTS
On March 31, 2010, a child (11 months old) was struck and killed by a vehicle. The
police briefly investigated several trucks within the neighborhood, one of them belonging to
Defendant. On June 22, 2012, Defendant was arrested for unrelated criminal charges. After 62
days in custody, Detective Merchant interrogated Defendant about the incident that occurred on
3. March 31, 2010. At the start of the investigation, Defendant expressed her desire to go home and
be with her kids. She was in an emotional state before she was read her Miranda rights.
Defendant was crying from the beginning of the interrogation, which was enhanced as Detective
Merchant mentioned her kids and husband.
Detective Merchant started expressing his opinions at the beginning of the interview. One
statement he made was, “…we feel comfortable we know what happened that day, it’s just trying
to put everything together, the pieces of the puzzle.” Further into the interrogation, Detective
Merchant expressed his opinion by saying, “But it would be—it would be tougher for somebody
to sit the rest of their life and have this on their chest knowing it was an accident.” Continuing
with expressing his opinion that Defendant was involved, he said, “And we do feel like a red
Dodge truck was involved, but, you know, once again, we’re only here to get the facts.”
Continuing a few minutes later, he says, “I’m sure whoever is responsible for it probably doesn’t
sleep well at night. They probably think about it every day. I’m sure it’s tough.”
As Detective Merchant continues stating his opinion and brings up Defendant’s kids,
Defendant continues to cry and repeatedlydeny her involvement. Detective Merchant than
mentions his opinion again and he states speculative facts. He begins to accuse her of her
involvement by the following quote:
“You’re a mother, Amanda, you’re an adult, you’re married, you’ve come a long ways in
life. There’s more to what happened that day and we’ve been putting the pieces together
for a long time. People are starting to come forward. People are saying, you know, this is
tough, why won’t they tell the truth, why don’t they tell the truth? It’s an accident. It’s an
accident. Why won’t they tell the truth? I can’t answer that question for the mom right
4. now, but I’d love to. And there’s—there’s one person that can answer that question right
now, and it’s you.”
Detective Merchant continues the interrogation with expressing his opinion with
statements that contain, “I think, I feel.” Detective Merchant states these opinions while
Defendant is crying, denying her involvement, and expressing her desire to go home and be with
her family.
ARGUMENT
I. DEFENDANT IS ENTITLED TO PROHIBITION BEFORE THE JURY OF HER
WRITTEN AND ORAL STATEMENTS BASED ON THE IMPERMISSIBLE
OPINION TESTIMONY MADE BY LAW ENFORCEMENT
Exclusion of any or all of the evidence is required if the value of such evidence is
substantially outweighed by the danger of unfair prejudice, confusion of the issues, misleading
the jury, and would serve only to inflame the jury. §90.403, Fla. Stat. (2010).
Here, Detective Merchant has repeatedly given his personal opinions on the case.
He went as far as putting the guilt on Defendant when he said, “why won’t they tell the truth? I
can’t answer that question for the mom right now, but I’d love to. And there’s—there’s one
person that can answer that question right now, and it’s you.” Detective Merchant also expressed
his opinion by saying that law enforcement knows Defendant was involved by saying, “And we
do feel like a red Dodge truck was involved, but, you know, once again, we’re only here to get
the facts.”
Allowing one witness to offer a personal view on the credibility of a fellow witness is an
invasion of the province of the jury to determine a witness's credibility." Seibert, 923 at 460, 472
5. (Fla. 2006), quoting Knowles v. State, 632 So. 2d 62, 65-66 (Fla. 1993). Moreover, "[i]t is
especially harmful for a police witness to give his opinion of a witnesses' credibility because of
the great WEIGHT afforded an officer's testimony." Page v. State, 733 So. 2d 1079, 1081 (Fla.
4th DCA 1999).
In Seibert, the defense attempted to suppress opinion statements at trial and the court
ruled against the defense. In comparison to the case at hand, the State may attempt to use the
ruling of Seibert to argue that Detective Merchant’s statements should be allowed. However, the
court concluded in Seibert that the officer did not answer the questions; thus, there was no
bolstering of the witness. Here, however, Detective Merchant answered questions and repeatedly
communicated lies. This creates an unfair biased to the jury since Detective Merchant is a law
enforcement officer, which gives more credibility to the officer’s testimony. Id. at 1081,
Martinez v. State, 761 So. 2d 1074, 1079 (Fla. 1993).
II. REDACTION OF DEFENDANT’S STATEMENT WOULD CONFUSE AND
MISLEAD THE JURY BY PRESENTATION OF HER RESPONSES WITHIN A
VACCUM ABSENT THE PERTINENT FACTS THAT PROMOTED HER
STATEMENT
If the State were to redact certain parts of the interrogation that were biased and
prejudicial, the jury would be misguided and misled from the testimony. In the case of Roundtree
v. State, 145 So. 3d 963, the trial court erred in admitting a video tapped interrogation that
expressed the officer’s opinion. The court stated:
Because a witness's opinion as to the credibility, guilt or innocence of the accused is
generally inadmissible, "it is especially troublesome when a jury is repeatedly exposed to
6. an interrogating officer's opinion regarding the guilt or innocence of the accused."
Jackson v. State, 107 So. 3d 328, 339-40 (Fla. 2012). Nonetheless, "a police officer's
statements during an interrogation are ADMISSABLE if they provoke a relevant
response or provide context to the interview such that a rational jury could recognize the
questions are interrogation techniques used to secure confessions." (Emphasis added) Id. at
340.
The State may argue that Detective Merchant’s statements to Defendant were to provoke
a relevant response, which would be admissible according to McWatters v. State, 36 So. 3d 613,
638 (Fla. 2010). However, McWatters is distinguished from the current case by the fact that
McWatters deals with evidence of the interrogation that provides the context for the
interrogation, and not for proving the truth of the matter assert. In the current case, Detective
Merchant repeatedly lied to Defendant about pertinent facts. Detective Merchant mentioned that
he talked to her husband and neighbors, which elicited an emotional response from Defendant.
Allowing this testimony would prejudice the jury.
There are numerous cases in which the trial court denied witness testimony based on
biased and unfair prejudice. See Martinez v. State, 761 So. 2d 1074, 1079 (Fla. 2000) (stating
that, generally, "a witness's opinion as to the guilt or innocence of the accused is not
ADMISSIBLE . . . on the grounds that its probative value is substantially outweighed by unfair
prejudice to the defendant") (emphasis added); see also Glendening v. State, 536 So. 2d 212, 221
(Fla. 1988) ("[a]ny probative value such an opinion [about the guilt or innocence of an accused]
may possess is clearly outweighed by the danger of unfair prejudice"); Mohr v. State, 927 So. 2d
1031, 1034 (Fla. 2d DCA 2006) (holding that appellate counsel's failure to argue the trial court
7. erred in admitting detective's statements advising the jury of his personal belief in the defendant's
guilt, theories as to why the defendant committed the offense, and theories why the victim was
honest, constituted ineffective assistance of counsel); Sparkman v. State, 902 So. 2d 253, 257-59
(Fla. 4th DCA 2005) (holding officer's out-of-court comments indicating his belief the defendant
killed the victim were so prejudicial that the erroneous ADMISSION of the statements could not
be considered harmless beyond a reasonable doubt) (emphasis added); Pausch [340] v. State,
596 So. 2d 1216, 1218-19 (Fla. 2d DCA 1992) (holding that ADMISSION of officer's statement
expressing his disbelief of the defendant's story and accusing her of lying and committing the
crime was reversible error). (Emphasis added) Jackson, 107 at 340.
Furthermore, it has been demonstrated that a jury will give more weight to the credibility
of a law enforcement officer when giving his or her witness testimony. See Tumblin v. State, 29
So. 3d 1093, 1101 (Fla. 2010) (quoting Bowles v. State, 381 So. 2d 326, 328 (Fla. 5th DCA
1980)); see also Martinez, 761 So. 2d at 1080 ("there is an increased danger of prejudice when
the investigating officer is allowed to express his or her opinion about the defendant's guilt").
CONCLUSION
For the foregoing reasons, this Court should prohibit presentation before the jury of her
written and oral statement based on the impermissible opinion testimony made by law
enforcement throughout the entirety of her recorded statement.
CERTIFICATE OF SERVICE
8. I hereby certify that on 2015, I electronically filed the foregoing Memorandum
In Support of Motion In Limine Regarding Impermissblae Law Enforcement Opinion Testimony
Throughout the Defendant’s Statement.
Respectfully Submitted,
_______________/s/________________
Rosemarie Peoples, Esq.
Fla. Bar#498238
Assistant Public Defender
Seventh Judicial Circuit
State of Florida